There are no guarantees in compliance, nor in most
cases can we offer them. For example, a request was made by a customer
who wanted me to sign a paper guaranteeing that our wireless system
when installed in his medical facility would not cause any, repeat
"any," harmful interference to his systems operating in
a facility I had never seen.
With the knowledge that if I signed such a document
our legal department would have me stood up in front of a wall and
shot, common sense reigned and I did not sign any document to that
effect. There was just no way to guarantee that.
I thought the matter had died until I was informed
by the vendor bidding on the project that I had lost the account
to his competitor who had signed such a document for the facility.
I asked the vendor why he did not sign the document since he was
designing and installing the system and it was his responsibility
to make sure the systems complied. He stated that we as the manufacturer
are responsible for compliance and should guarantee compliance in
all cases per the FCC rules.
Unfortunately, that is the belief of some, that the
manufacturer is responsible for the compliant operation of wireless
systems. This, however, is not true. The manufacturer is responsible
for designing the system to the required regulatory specifications
and making sure the product is properly certified before placing
it on the market. The manufacturer is also responsible to make sure
that information on operation and proper accessories such as approved
antennas is provided.
However, the system operator, whether a service provider,
licensed radio operator or, in the case of a Part 15 device, the
user is responsible for compliant operation of the device. Therefore,
if a vendor or customer buys a Part 15 WLAN radio and makes any
undue changes such as using a non approved antenna, a third party
amplifier, or makes any unauthorized changes, or installs it or
operates it improperly, then they are the responsible party for
addressing compliance.
Once again there will be a joint meeting of the RAC
and SAC committees at the 2002 IEEE International Symposium on EMC
in Minneapolis. It will be held on Monday, August 19th at noon at
the Hyatt Regency Hotel. At this time, I invite the RAC and SAC
members to attend this luncheon as well as the members of the EMC
Society Board of Directors. We will discuss several issues including
possible changes to the RAC. Hope to see everyone there. EMC
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